CFTC Staff Letters

Time-Limited No-Action Relief from (i) Parts 43 and 45 Reporting for Prime Brokerage Transactions, and (ii) Reporting of Unique Swap Identifiers in Related Trades under Part 45 by Prime Brokers

Request for Time-Limited No-Action Relief for Certain Swap Dealers from Compliance with Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers.

Clarification of Division of Market Oversight No-Action Letter 12-04 (July 17, 2012), and Extension of No-Action Relief for Non-Clearing Member Swap Dealers from Large Swap Trader Reporting Requirements of Section 20.4 of the Commission’s Regulations.

The Division of Market Oversight issued time-limited, no-action relief from the post-allocation swap timing requirement of section 45.3(e)(ii)(A) of the Commission’s regulations.

No-Action Relief: Alternative to Fingerprinting to Establish Fitness of Principals Residing Outside the United States.

Staff No-Action Relief: Preservation of the Regulatory Status Quo Established with Respect to Certain Transactions by the Commission’s Second Amendment to July 14, 2011 Order for Swap Regulation.

Request for Time-Limited No-Action Relief for Certain Futures Commission Merchants from Compliance with Certain Requirements of Commission Regulation 3.3 Relating to Annual Reports by Chief Compliance Officers.

Time-limited no-action relief for Part 20 Reporting Entities regarding identifying information and for Part 45 and Part 46 Reporting Counterparties regarding legal entity identifiers and other identifying information.

The Division of Swap Dealer and Intermediary Oversight issued a letter providing additional guidance to securitization vehicles regarding whether they may be excluded from the definition of commodity pool. The Division also stated that it will not recommend that the Commission take enforcement action against the commodity pool operators of securitization vehicles that have not and will not issue new securities on or after October 12, 2012. Finally, the Division stated that, for securitization vehicles that could not claim relief either under this letter or the 12-14 Letter, it would not recommend enforcement action against operators of securitization vehicles for failure to register as a commodity pool operator until March 31, 2013.

No-Action Relief from the Commodity Pool Operator Registration Requirement for Commodity Pool Operators of Certain Pooled Investment Vehicles Organized as Mortgage Real Estate Investment Trusts.